Vulnerable Customer Policy

1. POLICY STATEMENT

1.1 Our Commitment

Unicorn Currencies Limited (Canada) and Unicorn Currencies Ltd (United Kingdom) are committed to treating all clients fairly, ethically, and with dignity and respect. We recognize that some of our clients—including business owners, directors, and authorized signatories of corporate clients—may experience circumstances that make them vulnerable to harm, particularly financial harm.

This Vulnerable Customer Policy establishes our framework for: (a) Identifying clients who may be in vulnerable circumstances; (b) Understanding the specific needs of vulnerable clients; (c) Adapting our services, communications, and processes to meet those needs; (d) Training our staff to recognize and respond appropriately to vulnerability; (e) Monitoring outcomes to ensure vulnerable clients receive fair treatment and good outcomes; (f) Continuously improving our approach through feedback and review.

1.2 Regulatory Context

This policy aligns with FCA Consumer Duty (effective July 31, 2023), FCA Guidance on Fair Treatment of Vulnerable Customers (FG21/1), Treating Customers Fairly (TCF), Equality Act 2010 (UK), Canadian Human Rights Act, AODA and similar provincial legislation, and FINTRAC guidance on vulnerable persons.

1.3 B2B Context and Individual Decision-Makers

While Unicorn Currencies provides services to corporate clients, the individuals making decisions on behalf of those entities—business owners, directors, CFOs, treasurers, authorized signatories—are human beings who may experience vulnerability. Examples: sole proprietor experiencing bereavement; small business owner with mental health challenges during financial stress; elderly director with declining cognitive capacity; business owner facing financial difficulties or insolvency; authorized signatory with limited financial literacy pressured into complex hedging products; new entrepreneur with English as a second language. This policy recognizes that vulnerability can affect business decision-makers just as it affects retail consumers.

2. UNDERSTANDING VULNERABILITY

2.1 Definition

A vulnerable customer is someone who, due to their personal circumstances, is especially susceptible to harm—particularly when a firm is not acting with appropriate levels of care. Vulnerability is situational and contextual; multifaceted (health, life events, resilience, capability); variable in impact; temporary or permanent; often hidden.

Key Principle: Vulnerability is not about labeling individuals; it is about understanding circumstances that may increase the risk of harm and adapting our services to prevent that harm.

2.2 Drivers of Vulnerability (HRRC Framework)

Health: Physical or mental health conditions affecting ability to carry out day-to-day tasks or make decisions (e.g., serious illness, disability, depression, anxiety, cognitive impairments).

Resilience: Low ability to withstand financial or emotional shocks (e.g., business financial difficulties, over-indebtedness, stress, burnout).

Life Events: Major life events affecting ability to engage effectively (e.g., bereavement, relationship breakdown, caring responsibilities, job loss, business transitions, domestic abuse, legal or regulatory issues).

Capability: Low knowledge or confidence in managing finances, or low capability in literacy, digital skills, or language (e.g., limited FX understanding, first-time importers/exporters, ESL, elderly business owners, very young entrepreneurs).

Clients may experience multiple drivers simultaneously (intersectionality). Our approach tailors support to address multiple vulnerability drivers together.

3. IDENTIFYING VULNERABLE CLIENTS

We use multiple methods: (a) Client onboarding and application forms with optional questions inviting disclosure of circumstances requiring support; (b) Ongoing monitoring and staff observations (communication patterns, transaction patterns, account management indicators); (c) Data and analytics (age, geography, business type, transaction history, support requests); (d) External information sources (with client consent). We encourage and facilitate client self-disclosure. When vulnerability is identified, we record on client file, flag for visibility, limit access, obtain consent where necessary, and reassess periodically. All client-facing staff receive training on vulnerability indicators, asking sensitively, active listening, empathy, and escalation procedures.

4. SUPPORTING VULNERABLE CLIENTS

Principles: Individuality (tailoring support to each client); dignity and respect; empowerment (supporting informed decisions, not deciding for them); proportionality; flexibility; proactivity; consistency.

Communication Adjustments

Plain language; shorter sentences; explanations and examples; visual aids; checking understanding; written summaries; key facts documents; preferred channels (phone, email, video, in-person); large print and alternative formats; translation services; more time; multiple touchpoints; cooling-off periods; flexible deadlines; compassionate tone; patience; non-judgmental approach.

Product and Service Adjustments

Enhanced suitability assessments before recommending products; assess complexity, risk, and needs; consider alternatives (e.g., spot instead of forwards); document rationale; second opinion for complex products (forwards, options). Enhanced product warnings: clear risk warnings in plain language; worst-case scenarios; cooling-off period (at least 48 hours); confirmation of understanding. Simplified alternatives: spot transactions only where appropriate; smaller transaction sizes; guided process; pre-set limits; dedicated account manager. Flexibility and forbearance: payment plans, deadline extensions, fee waivers, renegotiation where commercially viable, hold on collections, referral to debt advice (StepChange, Citizens Advice, Credit Counselling Canada).

Process Adjustments

Onboarding: assisted onboarding, document assistance, alternative verification methods, home visits or video calls, third-party support, extended timelines. Transaction execution: verbal confirmation calls, written confirmations, cooling-off reminders, rate explanations, settlement reminders. Complaint handling: priority handling, empathetic response, plain-language explanations, reasonable adjustments, ombudsman signposting.

Safeguarding Against Financial Abuse

We remain vigilant for warning signs: sudden changes in transaction patterns or authorized signatories; undue influence by third parties; client confusion about transactions; isolation from advisors or family; unusual instructions; coercion indicators; deceptive documents. If financial abuse is suspected: speak to the client privately; verify instructions; escalate to Compliance Officer or COO; pause transactions where reasonable suspicion exists; file SAR if appropriate; report to authorities; support the client with information about support services. We presume capacity; support informed decisions; intervene only when there is clear evidence of abuse, coercion, or lack of capacity.

5. STAFF TRAINING AND COMPETENCE

All employees receive mandatory training: induction training within 30 days of hire (definition of vulnerability, HRRC framework, FCA Consumer Duty, identification, communication skills, support mechanisms, escalation, safeguarding, case studies); annual refresher training; role-specific training for client-facing teams, compliance, senior management, and product teams. We designate a Vulnerable Customer Lead (Head of Compliance) and Vulnerable Customer Champions within each department. We provide vulnerability identification checklist, communication guides, escalation flowchart, support services directory, and intranet resource hub.

6. MONITORING AND OVERSIGHT

We track KPIs: identification (number/percentage of vulnerable clients, method, demographics, trends); support and outcomes (support measures, product take-up, transaction outcomes, complaints, satisfaction, financial outcomes); process (training completion, escalation metrics, policy compliance, referrals). Quality assurance: call monitoring, email reviews, file reviews, mystery shopping, customer feedback. Reporting: quarterly to Senior Management; semi-annual to Board; regulatory reporting (Consumer Duty, FCA thematic reviews, FINTRAC). Annual internal audit of vulnerable customer policy compliance.

Key Questions